MEMORANDUM OPINION
WOODWARD, District Judge.
This civil action was filed by Etter Grain Company, Inc., against the United States of America for the refund of income taxes for fiscal years 1963, 1964, and 1966 through 1968 in the amount of $31,735.37. Alternatively, Plaintiff Etter Grain claims a refund in the amount of $36,199.02 for fiscal years 1964 through 1968. While this action was pending, the Internal Revenue Service assessed additional deficiencies...
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